People v. Arellano
REITERATIONFacts
The Antecedents: On October 29, 1937, the appellant, Marcos K. Arellano, applied for registration as a voter in San Manuel, Pangasinan. In his voter's affidavit, he answered 'Yes, with plenary pardon' to the question regarding whether he had been sentenced by final judgment for not less than eighteen months imprisonment. However, the pardon granted to him for a previous conviction was conditional, not absolute. Procedural History: The Court of First Instance of Pangasinan found the appellant guilty of violating Section 2465 of the Revised Administrative Code and imposed an indeterminate sentence of one to three months imprisonment, a fine of P100, subsidiary imprisonment in case of insolvency, and costs. The Petition: The appellant appealed the decision, contending that the facts proved did not constitute a violation of Section 2465 but rather Section 2647 of the Revised Administrative Code.
Issue(s)
Whether the facts proved constitute a violation of Section 2465 or Section 2647 of the Revised Administrative Code. Whether the appellant knowingly subscribed a false oath.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance of Pangasinan with a modification regarding the penalty, sentencing the appellant to three months imprisonment and deprivation of suffrage and disqualification from public office for four years.
Ratio Decidendi
On the applicable statute and the nature of the offense: The Court held that the act committed by the accused-appellant falls within the scope of Section 2465 of the Revised Administrative Code, which punishes "Perjury in election matter." This section penalizes any person who knowingly takes or subscribes any false oath, affidavit, or affirmation before any election officer, or before any court or other officer in relation to any material fact in any registration or election proceeding. The Court distinguished this from Section 2647, which deals with "Unlawful registration" and punishes those who cause their names to be registered knowing they are not qualified voters or who willfully give false answers relative to registration, with a specific defense if they did not vote. The Court emphasized that Section 2465 and Section 2647 define and punish two distinct and separate offenses. On whether the oath was knowingly false: The Court rejected the appellant's defense that he did not know his pardon was conditional. It reasoned that the appellant had his pardon in his possession, and the conditions of the pardon were clearly stated in the communication from the Governor General ordering his release. Therefore, he must have known, or at least should have known, that his pardon was not absolute when he subscribed to the affidavit claiming it was. The defense that he refrained from voting upon discovering the conditional nature of the pardon was also dismissed as not establishing that he did not subscribe his oath knowingly.
Main Doctrine
The act of knowingly subscribing a false oath or affidavit before an election officer in relation to a material fact in any registration proceeding constitutes perjury under Section 2465 of the Revised Administrative Code, irrespective of whether the registrant voted or not, and is distinct from the offense of unlawful registration under Section 2647 of the same Code.